“­Instead of listing examples in Appendix II, it may be better in paragraph 32 only to refer to existing guidance by Parties (see original footnotes 21-23) under PACE and MPPI.”

From p. 1 of European Union response to Basel Secretariat. 2011. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version: 21 February 2011 )’. http://archive.basel.int/techmatters/code/comments.php?guidId=78

“[ITI Comment: This section [proposed list of functionality test] for reviewed following completion of the PACE guidelines.]”

From p. 20 of response by Information Technology Industry Council (ITI) to Basel Secretariat. 2011. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version: 21 February 2011 )’. http://archive.basel.int/techmatters/code/comments.php?guidId=78

“To the extent practicable, the guidance should remain consistent with the approaches adopted under both the Basel Mobile Phone Partnership Initiative (MPPI) and Partnership on Action for Computing Equipment (PACE), which do not list equipment as hazardous or non-hazardous waste”

From p. 2 of response by Canada to Basel Secretariat. 2012. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version 8 May 2012)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.

“We are of the opinion that if we are to keep appendix II it needs to be developed further in accordance with the draft PACE guideline (table 1 in 3.1.11 of reuse and refurbishment guideline) and MPPI. However, deleting the appendix and rather include references in the text of the E-waste guideline is also fine.”

From p. 2 of response by Norway to Basel Secretariat. 2012. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version 8 May 2012)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.

“As stated above, we do not support the addition of BAN’s text and associated table providing examples of hazards in electronic equipment. First, there are a number of inaccurate entries based upon assumptions that are not agreed upon by the Basel Parties within BAN’s table. Additionally, there is an overarching CLI initiative that is currently working on legal clarity with regards to terms and definitions under the Convention that are lacking or ambiguous. The CLI initiative effort is broader in scope; the proposed appendix by BAN pre-empts these efforts. These technical guidelines should focus on transboundary movement procedures pursuant to those defined within the PACE and MPPI and not aspire to classify waste versus non-waste.”

From p. 2 of United States response to Basel Secretariat. 2012. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version 8 May 2012)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.